[DEFENDANT’S NAME], DEFENDANT’S INTERROGATORIES …

1 SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION Landlord And Tenant Branch ) [PLAINTIFF S NAME], ) ) Plaintiff, ) ) v. ) L&T No. [CASE NUMBER] ) [DEFENDANT S NAME], ) ) Defendant. ) ) DEFENDANT S INTERROGATORIES TO PLAINTIFF To: PLAINTIFF S NAME] c/o: [PLAINTIFF S COUNSEL S NAME AND ADDRESS] Defendant propounds the following INTERROGATORIES to plaintiff under Rule 33 of the Superior Court Rules of Civil Procedure made applicable to the Landlord Tenant Branch by SCR-LT Rule 10: INSTRUCTIONS 1. Each interrogatory should be responded to upon your entire knowledge from all sources and all information in your possession or otherwise available to you, including information from officers, employees, agents, representatives, consultants, or attorneys, and information which is known to each of them.

2 Every document or source of information including those not within your NOTE: Generally, only 10 INTERROGATORIES are allowed. - 2 - immediate or direct control must be consulted in responding to each interrogatory propounded herein. 2. If any of the following written INTERROGATORIES cannot be responded to in full, respond to the extent possible, specifying the reason for your inability to respond to the remainder, and stating all information or knowledge you have concerning the responded to portion. If your responses are qualified in any respect, set forth the terms and explanations of each such qualification.

3 3. If any response is given which states an objection to the INTERROGATORIES on any ground, state said grounds completely. If the interrogatory is only partly objectionable, respond to the remainder of the interrogatory as set forth above. If the response to an interrogatory is not within the personal knowledge or possession of the signatory to the INTERROGATORIES , the response shall identify the person from whom the information or document was obtained, and shall be accompanied by affidavit from said person attesting to the truthfulness of the answer. 4. In answering each interrogatory: a) Identify by description, date, sender, recipient, location and custodian each document relied upon or which forms a basis for the answer given or which corroborates the answer given or the substance of what is given in answer to these INTERROGATORIES ; b) State whether the information furnished is within the personal knowledge of the person answering, and, if not, identify each person to whom the information is a matter of personal knowledge.

4 And c) Identify each person who assisted or participated in preparing and/or supplying any of the information given in answer to, or relied upon in preparing answers to, these INTERROGATORIES . - 3 - 5. Each interrogatory should be answered separately. INTERROGATORIES should not be combined for the purpose of supplying a common answer. An interrogatory should not be answered by referring to the answer of another interrogatory unless the answers are identical. 6. If you are asked to describe a particular document, the description should include the date the document was generated, the identity, address and phone number of the generator and custodian of the document, the nature of the document, and the information contained therein.

5 7. If you are asked to describe a particular event, the description should include a detailed statement of what transpired, the name, address and telephone number of each and every witness to the event, the date the event occurred, and every action which you may have taken in response to the event described. If there is more than one event described in response to the interrogatory, your response should clearly delineate between the events and a full description, as provided herein, should be given for each separate event. 8. These INTERROGATORIES are continuing in character, so as to require you to file supplemental responses if you obtain different and/or additional information and/or documents prior to and including the date of trial.

6 9. You are required to serve a copy of your response to the INTERROGATORIES , under oath, upon [NAME], attorney for defendant, [ADDRESS], within 30 days after service of the same upon you. DEFINITIONS The following definitions form an integral part of these INTERROGATORIES : 1. Document(s) : The term document(s) means any written , printed, typed or other graphic matter of any kind or nature, including drafts and all copies bearing notations or marks not found on the original and includes, but is not limited to: - 4 - (a) All contracts, agreements, representations, warranties, certificates, opinions.

7 (b) all letters or other forms of correspondence or communication, including envelopes, notes, telegrams, cables, telex messages, messages (including reports, notes, notations, recordings, transcripts, and memoranda of or relating to telephone conversations or conferences); (c) All memoranda, reports, financial statements or reports, notes, transcripts, tabulations, studies, analyses, evaluations, projections, work papers, charts, graphs, extracts, statistical records, compilations; (d) All desk calendars, appointment books, diaries; (e) Newspapers, booklets, circulars, bulletins, notices, instruction manuals; (f) All minutes or transcripts of all meetings; (g) All photographs, microfilms, phonographs, tapes, or other records, punch cards, magnetic tapes, disc, data cells, drums, printouts, and other data compilations, from which information can be obtained (translated through detection devices into useable form).

8 2. Person(s) : The term person(s) as used herein means a natural person, partnership, joint venture, corporation, business trust company, association, firm, society, joint stock company, and any other form of legal entity, unless the context otherwise requires. 3. Communication : The term communication(s) as used herein means any written or oral contact, formal or informal, at any time or place, and under any circumstances whatsoever, whereby information of any nature was transmitted and transferred. It includes, but is not limited to, meetings, telephone conversations, discussions, reports, executive summaries, briefings, and oral requests for information.

9 It includes, but is not limited to, letters, notes, notices, - 5 - pleadings and other legal filings, memoranda, advertisements, post cards, and telegrams. 4. Identify or identity means: (a) With respect to a person, his or her name, present or last known home address and telephone number, present or last known place of employment, including address and telephone number, and each office, title or position, if any, held at any time with plaintiff, and the nature of his or her relationship with plaintiff, past and present. (b) With respect to a contract, instrument or document: (i) Which exists and is currently in possession of or obtainable by plaintiff or its agents (including, but not limited to, its attorneys), the type of document ( , letter, memorandum, record, list, report, charts, etc.)

10 , date, identification of the person or persons who prepared the document, identification of the person for whom the document was prepared, the name(s) of each signatory thereof, and to whom it was delivered, and the identification of the present custodian and current location of that document; (ii) Known to have existed but no longer existing, the type of document, ( , letter, memorandum, record, list, report, chart, etc.), its last custodian, and the date and circumstances under which the document was lost, destroyed or became unavailable; - 6 - (iii) Formerly in the possession of plaintiff or its agent (including, but not limited to, its attorneys) but no longer in its possession, the type of document, the date and the circumstances under which the document left the possession of the plaintiff and the identification of its present custodian and location.